Simon v. Adzilla, Inc [New Media] et al

Filing 49

STIPULATION re 9 MOTION to Dismiss for Lack of Jurisdiction Notice of Motion and Motion to Dismiss First Amended Complaint for Lack of Personal Jurisdiction and supporting memo by Susan Simon. (Attachments: # 1 Proposed Order)(Himmelfarb, Alan) (Filed on 7/15/2009)

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Simon v. Adzilla, Inc [New Media] et al Doc. 49 Case3:09-cv-00879-MMC Document49 Filed07/15/09 Page1 of 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Pursuant to Civil Local Rule 6-1, Plaintiff and Defendant Continental Visinet Broadband LLC ("Continental Visinet") hereby stipulate and agree as follows: 1. The time for Plaintiff to file a response to Continental Visinet's Motion to Dismiss v. Alan Himmelfarb - SBN 90480 KAMBEREDELSON, LLC 2757 Leonis Boulevard Vernon, California 90058 Telephone: (323) 585-8696 Joseph H. Malley - TX SBN: 12865900 LAW OFFICE OF JOSEPH H. MALLEY, P.C. 1045 North Zang Boulevard Dallas, Texas 75208 Ph. (214) 943-6100 Fax (214) 943-6170 Counsel for Plaintiff UNITED STATES DISTRICT COURT NORTHERN DISTRICT SAN FRANCISCO DIVISION SUSAN SIMON, individual, on behalf of herself and all others similarly situated, Plaintiff, CASE NO. 3:09-cv-00879-MMC THIRD STIPULATION REGARDING TIME FOR PLAINTIFF'S RESPONSE TO DEFENDANT CONTINENTAL VISINET BROADBAND LLC'S MOTION TO DISMISS AND TO CONTINUE HEARING DATE ADZILLA, INC. [NEW MEDIA], a Delaware Corporation; CONDUCIVE The Hon. Maxine M. Chesney CORPORATION, a Delaware Corporation; CONTINENTAL VISINET BROADBAND, INC., a Delaware Corporation; CORE COMMUNICATIONS, INC., d/b/a CORETEL COMMUNICATIONS, INC., a Delaware Corporation; AND JOHN DOES 1-50, Corporations Defendants, Defendants. (Dkt. No. 9) is extended to August 7, 2009. STIPULATION RE CONTINENTAL VISINET MOTION TO DISMISS 3:09-CV-00879-MMC Case3:09-cv-00879-MMC Document49 Filed07/15/09 Page2 of 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2. 3. 4. Plaintiff filed her complaint on February 27, 2009. Continental Visinet filed its Motion to Dismiss on March 30, 2009. This is the third request for an extension of time concerning a response to Continental Visinet's Motion to Dismiss. 5. The parties request this extension to allow Plaintiff and Defendant Continental Visinet to finalize their discussions regarding a non-judicial resolution of the matter through informal discussions. The parties have agreed in principal to such a resolution and require additional time in which to finalize details to formally implement the non-judicial resolution as to Continental Visinet. 6. This requested time modification will require the Court to reschedule the hearing on Defendant Continental Visinet's Motion to Dismiss, which is currently scheduled for July 31, 2009 at 9:00 a.m. The parties propose that the Court reschedule the hearing for Friday, August 28, 2009 at 9:00 a.m. Dated: July 15, 2009 By: /s / Alan Himmelfarb KAMBEREDELSON, LLC Attorney for Plaintiffs By: /s/ Martin L. Fineman DAVIS WRIGHT TREMAINE LLP Attorney for Defendant Continental Visinet Broadband LLC. Dated: July 15, 2009 Third Stipulation Regarding Time for Plaintiff's Response to Defendant Continental Visinet's Motion to Dismiss and to Continue Hearing -2- 3:09-CV-00879-MMC

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